The TPA Transfer Pricing Global Documentation Handbook
The “TPA: Transfer Pricing Global Documentation Handbook – December 2023” is a comprehensive guide for multinational companies navigating…
Read more →SOUTH AFRICA: MY TAKE ON THE 2024 BUDGET SPEECH
The 2024 Budget Speech underscores a commitment to implementing a Global Minimum Tax, aligning with international efforts to curtail tax…
Read more →BOOK UPDATE: “CONDUCTING A TP TRIAL” – CHAPTER 1 NOW AVAILABLE
Having prepared and argued at numerous Transfer Pricing trials, I thought it a good idea to commit my journey and experiences to paper as a…
Read more →SOUTH AFRICA: Kusasa Refining (Pty) Ltd v Commissioner for South African Revenue Services
The case involves the failure of SARS to finalize the value added tax (VAT) audit of Kusasa Refining for the period from January 2019 to…
Read more →FREE Online Workshop: Conducting a Transfer Pricing Trial
Learn how to best Conduct a Transfer Pricing Trial with leading experts Prof. Dr. Daniel N Erasmus and Mr. Renier van Rensburg from…
Read more →Estate Duty in African Nations
Old Ben Franklin said that nothing in the world is certain except death and taxes. Most people find both subjects disagreeable, and…
Read more →TRYING TO SETTLE TAX DISPUTES OUTSIDE THE PARAMETERS OF TAX LEGISLATION
This reminds me of a recent issue raised by a client MNE in Africa. The taxpayer was facing a revised tax assessment and had to pay 30% of…
Read more →GTC Conference 2023
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:…
Read more →Emerging Trends in Transfer Pricing
Transfer pricing (TP) disputes have always posed challenges to multinational enterprises (MNEs) and tax authorities. The interpretation and…
Read more →Unlocking the Complexities of Tax Dispute Resolution in South Africa:
In the ever-evolving landscape of taxation, the ability to navigate tax disputes effectively is more crucial than ever. I am thrilled to…
Read more →EU Tax Law
Dr. Erasmus, with his expertise in tax law, can provide valuable guidance on navigating the complexities of EU tax regulations, helping…
Read more →Dispute Resolutions
We’ve honed our skills on dispute resolutions internationally, involving various tax authorities. We have a record of settling for less…
Read more →SOUTH AFRICAN INSTITUTE OF TAXATION (SAIT) Transfer Pricing Summit 2023
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:…
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Apple vs. European Commission
This case revolves around the European Commission’s appeal against the General Court’s decision to annul the Commission’s ruling that…
Read more →TPMinds Africa: 07 – 08 November 2023
I/I/T/F Head of Academic Development, Prof Dr Daniel N. Erasmus was in attendance at the event and delivered a key-note presentation on:…
Read more →Stora Enso Wood Products vs Czechia
The Supreme Administrative Court (SACC) of the Czech Republic annulled the judgment of the Regional Court in Hradec Králové, which had…
Read more →Boston Scientific v. CIT (India): Permanent Establishment and TP Implications
This case, heard by the Indian courts, raises significant issues concerning the activities that constitute a PE, especially in relation to…
Read more →CEPSA’s Transfer Pricing Case: Spain vs Compañía Española de Petróleos (CEPSA)
The Supreme Court ruled on the tax dispute between the Spanish tax authorities and CEPSA concerning the allocation of general management…
Read more →Germany vs “MEAT PE”: Taxation of the Domestic Permanent Establishment of a Hungarian…
This case examines the taxation of the domestic permanent establishment of a Hungarian corporation operating in Germany. The central issue…
Read more →ST Dupont vs. France Transfer Pricing Judgment
ST Dupont, a French luxury manufacturer, contested additional tax assessments and penalties imposed by the French tax authorities for the…
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Sociedade Unipessoal, LDA vs Portugal
This case involves a dispute over the deductibility of financial costs related to loans taken out by the taxpayer (A…, Sociedade…
Read more →Germany vs “Z Pipeline”: Transfer Pricing Disputes in Multinational Operations
The FG Düsseldorf judgment of May 12, 2023, revolves around the transfer pricing dispute of a multinational enterprise operating a pipeline…
Read more →Dart Sudamericana Transfer Pricing Case
The case revolves around the transfer pricing methods used by Dart Sudamericana S.A. for the importation of EPS pellets from related…
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Skechers USA Inc. vs. USA
The Wisconsin Tax Appeals Commission ruled in favour of the Wisconsin Department of Revenue, affirming its disallowance of royalty…
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